We are excited to launch our "Sanctions in Focus" series, featuring five concise posts that explore the challenges firms face in navigating the ever-evolving landscape of sanction management. This series will provide insights on how to strengthen your current sanction protocols, redefine your operational model, and implement cutting-edge technology to streamline and enhance labour-intensive sanction operations.
The past 25 years have marked a dramatic transformation in how sanctions are used—not just as instruments of diplomacy, but as tools of influence, deterrence, and national security. For the UK, sanctions have become a vital part of foreign policy, financial integrity, and global leadership. Sonny Davies explains why horizon scanning—the ability to anticipate emerging risks and prepare for them—is essential.
A Recent History of Sanctions
In the early 2000s, sanctions were primarily shaped through multilateral institutions such as the UN and EU. The UK played a key role in driving sanctions in response to major conflicts like the Iraq War and the international response to the Taliban regime in Afghanistan. These sanctions were relatively conventional - arms embargoes, asset freezes, and travel bans targeting regimes and known associates.
The 2010s, however, saw a pivot toward thematic and targeted sanctions. The Syria conflict, growing concerns around Iran’s nuclear programme, and North Korea’s missile tests all saw sanctions become more sophisticated and globally coordinated. In these years, the focus expanded from state actors to networks—individuals, front companies, financial facilitators—requiring greater diligence from UK firms in identifying indirect risks and hidden exposure.
The 2014 Crimea crisis marked a turning point. The coordinated Western sanctions response - driven by the US and EU and backed by the UK—introduced a new category of sectoral restrictions on finance, energy, and defence. It also seeded what would become a complex, evolving regime requiring real-time screening and due diligence far beyond simple list-matching.
Sanctions 2.0
Following the UK's departure from the EU, the establishment of the UK Sanctions and Anti-Money Laundering Act 2018 gave the UK independent powers to design and implement sanctions. This autonomy was quickly tested with the 2022 full-scale invasion of Ukraine by Russia. The UK moved decisively, introducing thousands of asset freezes, export bans, and restrictions on central bank assets, oligarchs, and key sectors. The speed, scope, and complexity of these measures challenged even the most sophisticated compliance functions. In this post-Brexit era, sanctions autonomy has enabled a more agile and values-driven approach.
Following the UK's departure from the EU, the establishment of the UK Sanctions and Anti-Money Laundering Act 2018 gave the UK independent powers to design and implement sanctions.
Moreover, UK enforcement is growing teeth. The Office of Financial Sanctions Implementation (OFSI) has increased its visibility and activity, issuing record fines and making clear that failure to maintain effective sanctions compliance frameworks will carry financial and reputational consequences. In today’s environment, ineffective screening systems, inadequate beneficial ownership checks, and sluggish list adoption can leave firms dangerously exposed.
Beyond Borders – How Sanctions are Evolving
But the complexity doesn’t stop there. Sanctions are no longer just about geography—they are increasingly thematic. The UK’s Global Human Rights and Anti-Corruption Sanctions Regimes now allow the government to respond to violations regardless of borders, with designations tied to behaviour rather than nationality. New restrictions on dual-use goods, export controls linked to emerging technologies like AI and quantum computing, and sanctions aimed at cyber attackers all show the expanding scope of UK sanctions policy.
Sanctions are no longer just about geography—they are increasingly thematic.
Why Horizon Scanning Matters
In this landscape, it’s no longer enough for firms to look in the rear-view mirror. Horizon scanning—the ability to anticipate emerging risks and prepare for them—is essential. UK-based firms, particularly those with international footprints or links to sensitive supply chains, must embed forward-looking geopolitical risk into their compliance and strategic planning.
The ability to anticipate emerging risks and prepare for them is essential.
This need is only growing. The geopolitical outlook for 2025 and beyond is uncertain. A return of Donald Trump to the US presidency and the ever-changing tariffs and unpredictable foreign policy shifts are placing strain on the economy. China’s position in the global economy continues to prompt reassessments around technology dependencies and national security. The UK's own trajectory in global leadership—across green technology, AI governance, and financial transparency—may well be enforced through sanctions policy.
Sanctions - A New Era of Business Risk
The firms best placed to thrive in this new sanctions era will be those that prioritise resilience:
- Screening tools must evolve beyond simple list-matching, accounting for complex ownership structures and emerging typologies.
- Dual-use goods and export control compliance must be robust and risk-based.
- Political and regulatory intelligence should be integrated into board-level risk conversations.
- Supply chains must be audited for indirect exposure to sanctioned entities, particularly in high-risk jurisdictions.
- Sanctions governance must extend beyond legal and compliance teams, becoming a cross-functional priority across procurement, sales, and finance.
The UK sanctions regime of the next 25 years will continue to evolve - not just in complexity, but in speed, thematic scope, and political visibility. Sanctions are no longer the domain of specialists; they are a strategic business risk that demands enterprise-wide awareness and action.
Sanctions are no longer the domain of specialists; they are a strategic business risk that demands enterprise-wide awareness and action.
Over Projective Group
Projective Group is opgericht in 2006 en is een toonaangevende change specialist voor de financiële dienstverlening.
We worden binnen de sector erkend als een provider van complete oplossingen, die samenwerkt met klanten in de financiële dienstverlening om oplossingen te bieden die zowel holistisch als pragmatisch zijn. We hebben ons ontwikkeld tot een betrouwbare partner voor bedrijven die willen gedijen en bloeien in een steeds veranderend landschap van financiële dienstverlening.
At Projective Group, we recognise that today’s sanctions landscape demands not just compliance, but strategic foresight. Our deep talent pool - trained in Financial Crime, Customer Due Diligence, and Sanctions - enables us to rapidly mobilise expert teams to support either BAU operations or ad-hoc remediation and implementation projects. Whether you need to strengthen your sanctions control frameworks, improve horizon scanning capabilities, or build resilience into your compliance functions, Projective Group can deliver the expertise and agility needed to stay ahead of an evolving regulatory environment.